Matthew C. Sperry

Matthew Sperry, a partner in the firm's Trusts and Estates practice, is an international private client lawyer that represents US and non-US high-net-worth individuals, families and family offices on international tax, private client, direct investing and securities matters. He regularly works with clients on foreign trust structures, pre-immigration planning for individuals desiring to become US resident, expatriation planning for US citizens desiring to exit the US, and managing global information and tax reporting obligations. Matthew's client base includes individuals and families resident throughout the world, including Asia, Latin America, the Middle East, Europe and Canada.

Matthew routinely develops solutions for the complex tax issues confronted by global high-net-worth individuals and families and family offices as they interact with the United States. He has extensive experience designing and implementing integrated family trust structures that solve for global taxation challenges, privacy, wealth transfer and succession, asset protection and global information compliance (such as under FATCA and the global common reporting standards (CRS)). He regularly assists clients in the architecture, execution and operation of their family offices.

In addition, Matthew offers a comprehensive approach aimed at addressing the particular legal and family needs in connection with direct investing activities, including those related to privacy, asset protection and cross-border tax structuring. He regularly assists clients in navigating the complex cultural, legal, tax and business challenges posed by cross-border direct investing transactions.

Matthew's clients also include private investment funds, private equity managers, venture capital firms and commodity pool operators. He has broad experience dealing with the securities issues that can arise when families desire to raise capital from sources both within and outside of the United States.

Chambers USA recognizes Matthew as a leading individual in the area of Private Wealth Law, described by a commentator as "practical" and "dependable" — an adviser who "takes the time to understand the client's needs and is willing to invest in the relationship."

Matthew regularly travels within the United States and throughout the world to provide his clients with personal attention and superior service. He regularly works with other family advisers (including accountants, lawyers, trustees and financial advisers) both within and outside of the United States to provide advice to clients that interact with multiple countries.

Matthew's tax experience includes serving as a federal law clerk to Judge Carolyn P. Chiechi of the United States Tax Court in Washington, DC.

Shown below is a selection of Matthew’s engagements.

Experience

While at a prior firm:

Representation of a London-based sponsor of private US real estate investments for global ultra-high-net-worth families and family offices. Designed and implemented investment structures to shield non-US investors from US estate taxes while minimizing US income tax leakage; addressed investor concerns regarding US tax reporting such as how to manage tax reporting so that they personally do not have to file income tax returns in the United States; advised as to each investment structure’s requirements under US FATCA and global Common Reporting Standards; and identified and solved US tax issues that arose post-investment, including when non-US family investors wanted to sell or otherwise redeem their investments.

Representation of a prominent US family with an existing US-based family office in establishing a new family office branch in Switzerland.

Representation of a UK-based family office of an ultra-high-net-worth Asian family in connection with a comprehensive review of the US tax exposure related to the family office’s activities in the United States.

Design and implementation of a US tax-efficient structure to permit an ultra-high-net-worth Mexican family to gift global family assets to their US-resident child.

Representation of one of the leading Channel Islands-based trust companies in providing US estate and income tax advice in connection with re-domiciling a non-US trust structure (for the benefit of an ultra-high-net-worth Middle Eastern family) from South America to the Channel Islands.

Representation of a Zurich-based trust company in connection with the US tax consequences of a proposed plan to decant a series of longstanding non-US trusts to new non-US trusts.

Engagement by a Zurich-based trust company to identify the US estate, gift and income tax exposure to a longstanding non-US trust settled by an ultra-high-net-worth US family. Identified all US tax-related issues and formulated a strategy to ameliorate such issues. Also developed a global restructuring plan to reorganize trust assets in a US tax-efficient manner.

Representation of a US- and Singapore-based sponsor of US real estate investments for ultra-high-net-worth Asian individuals and families. Provided US tax structuring and investment fund advice to facilitate pooled investments of Asia-based private capital, ultimately eliminating US estate tax exposure while maximizing investor returns on an after-tax basis.

Representation of a Fortune Global 100 company in its disposition of a global manufacturing division conducting business in more than 25 countries, leading a cross-border team of 20+ lawyers.

Representation of the family office of an ultra-high-net-worth family in its investment in global oil and gas properties, including the negotiation of a long-term development arrangement.

Representation of a Fortune Global 100 company in its acquisition of a water treatment business conducted in 15 countries.

Representation of the family office of an ultra-high-net-worth family in its acquisition of a Manhattan hotel and its redevelopment into a mixed-use project.

Representation of an ultra-high-net-worth family in its acquisition of a global hotel management company.

Representation of the family office of an ultra-high-net-worth family in its acquisition of a German-based manufacturer of precision industrial equipment.

Representation of the family office of an ultra-high-net-worth family in its acquisition in a Section 363 bankruptcy proceeding of a leading developer of road and paving technologies.

Representation of a Fortune Global 500 company in its disposition of its coffee business to a strategic buyer.

Representation of an ultra-high-net-worth family in its acquisition of numerous private aircraft, including developing and implementing a tax-efficient structure for the aircraft and registering the aircraft with the FAA.

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